Amazon Goldcrest Project and the Relevance of Comparability Analysis under the Arm's Length Principle

Authors

Reuven S. Avi-Yonah, University of Michigan Law SchoolFollow

Document Type

Article

Publication Date

5-2019

Abstract

The arm’s length principle, which has long been the guiding rule in the area of transfer pricing, in recent years is increasingly challenged. One of the focus points of discussion is the comparability analysis of intra-group and independent transactions. Especially intangibles do not lend themselves to such analysis, because they are unique in a way that does not match with existent market equilibria. The analysis of the Amazon case in this article reflects this argument.

Comments

Use is with the permission of Thomson Reuters. Originally published as Avi-Yonah, Reuven S. "Amazon Goldcrest Project and the Relevance of Comparability Analysis under the Arm's Length Principle." Andrea Musselli, co-author. Int'l Transfer Pricing J. 26, no. 3 (2019): 159-66.

Recommended Citation

Avi-Yonah, Reuven S. "Amazon Goldcrest Project and the Relevance of Comparability Analysis under the Arm's Length Principle." Andrea Musselli, co-author. Int'l Transfer Pricing J. 26, no. 3 (2019): 159-66.